Winfred Beasley v. Warren Unilube, Inc., 933 F.3d 932

Background

Beasley, an African American, worked as Quality Assurance Manager at Warren Unilube from Oct 2012 to Aug 2015; his duties included ensuring correct labeling/packaging, supervising inspectors, troubleshooting, and handling the annual ISO audit.
During his tenure Warren received multiple customer complaints (labeling/packaging in 2013, dye/odor and leaking caps in 2015) and the May 2015 ISO audit reported six minor deficiencies and criticized the quality program.
Warren disciplined several managers for related problems (Operations Manager Rusty Brown and others were disciplined; the Blending Manager was later fired); Beasley was criticized in a June 2015 letter for organizational and documentation deficiencies and was terminated in August 2015; his replacement was white.
Beasley filed EEOC charges alleging race discrimination under Title VII and 42 U.S.C. § 1981; EEOC dismissed and Beasley sued; the district court granted Warren summary judgment.
On appeal, the Eighth Circuit reviewed de novo, applied McDonnell Douglas burden-shifting, found Beasley made a prima facie case (replaced by a white male) but that Warren offered legitimate nondiscriminatory reasons, and concluded Beasley failed to show pretext or intentional discrimination.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Beasley can establish a prima facie Title VII/§1981 claim for discriminatory discharge	Beasley argued he was fired because of race and was replaced by a white male, supporting an inference of discrimination	Warren conceded nondiscriminatory performance issues but argued those justified the firing	Court: Beasley satisfied prima facie element by showing he was replaced by a white male
Whether Warren provided a legitimate, nondiscriminatory reason for termination	Beasley contended cited performance issues were pretext	Warren pointed to customer complaints, ISO audit deficiencies, and documented performance problems	Court: Warren met its burden by articulating legitimate nondiscriminatory reasons
Whether Beasley proved those reasons were pretext for racial discrimination	Beasley pointed to disparate treatment of African-American employees and argued similarly situated white managers were treated better	Warren argued comparators were not similarly situated and discipline of other white managers undermined inference of race-based motive	Court: Beasley failed to show comparators were similarly situated or otherwise demonstrate intentional discrimination; no pretext shown
Whether circumstantial evidence (pattern/practice) supported an inference of racial animus	Beasley argued pattern of treatment toward African-American employees suggested animus but provided limited supporting data	Warren noted discipline and firing of white managers and absence of statistical or concrete pattern evidence	Court: Evidence insufficient to tie termination to racial animus; claim fails

Key Cases Cited

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes burden-shifting framework for disparate-treatment claims)
Torgerson v. City of Rochester, 643 F.3d 1031 (Eighth Circuit en banc: summary judgment standard and application in discrimination cases)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (plaintiff retains ultimate burden to prove intentional discrimination)
Texas Dep't of Community Affairs v. Burdine, 450 U.S. 248 (employer must articulate legitimate nondiscriminatory reason; shifting burdens)
Johnson v. Securitas Sec. Servs. USA, Inc., 769 F.3d 605 (Eighth Circuit en banc: rigorous similarly-situated comparator standard)
Rodgers v. U.S. Bank, N.A., 417 F.3d 845 (discussion of comparator evidence and prima facie case)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (summary judgment standard: plaintiff must show genuine issue of material fact)